Now, the draft #standard for #CRA compliance for router/modems/switches is available (with no paywall again). Please direct any comments to your national standards organisation, which is constructing a formal response.
Development of this standard was extensively supported by open source community members from Debian - many thanks to them!
https://www.etsi.org/deliver/etsi_en/304600_304699/304627/01.00.01_20/en_304627v010001ev.pdf